principles rule (Pennsylvania) · Go Syfert
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principles rule in Pennsylvania

33 Pennsylvania opinions name it 6 courts 1839–2025 4 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
Kramer v. Schaeffergreen
pasuperct · 2000 · cited in 2 Pennsylvania opinions naming this issue, 2015–2023
2 sentences

2023Id. at 246 (cleaned up).

2015Kramer v. Schaeffer, 751 A.2d 241, 246 (Pa. Super. 2000) (internal citations and quotations omitted).

22
Commonwealth v. Gumpertgreen
pa · 1986 · cited in 2 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021See, e.g., Commonwealth v. Gumpert, 512 A.2d 699, 701-03 (Pa.Super. 1986) (holding that where a defendant failed to object to the complete absence of a jury waiver colloquy before the trial court, the issue was waived “insofar as the trial court was denied an opportunity to correct the deficiency”);2 see also Pa.R.A.P. 302(a) (“Issues not raised in the trial court are waived and cannot be raised for the first time on appeal.”).

2021See, e.g., Commonwealth v. Gumpert, 512 A.2d 699, 701-03 (Pa.Super. 1986) (holding that where a defendant failed to object to the complete absence of a jury waiver colloquy before the trial court, the issue was waived “insofar as the trial court was denied an opportunity to correct the deficiency”);2 see also Pa.R.A.P. 302(a) (“Issues not raised in the trial court are waived and cannot be raised for the first time on appeal.”).

22
Reisman v. Ranoel Realty Co.green
pasuperct · 1973 · cited in 2 Pennsylvania opinions naming this issue, 2009–2015
2 sentences

2015Co. v. Fioravanti, 451 Pa. 108 , 299 A.2d 585, 588 (1973) (once a dispute has been submitted to arbitration, the parties are entitled to a hearing with “the necessary essentials of due process, i.e., notice and opportunity to be heard and to defend in an orderly proceeding adapted to the nature of the case before a tribunal having jurisdiction of the cause.”); Reisman v. Ranoel Realty Co., 224 Pa. Super. 220 , 303 A.2d 511, 514 (1973) (arbitrations are not wholly informal proceedings and the basic principles of hearing conduct must be adhered to, with the arbitration process requiring for its

2015Co. v. Fioravanti, 451 Pa. 108 , 299 A.2d 585, 588 (1973) (once a dispute has been submitted to arbitration, the parties are entitled to a hearing with “the necessary essentials of due process, i.e., notice and opportunity to be heard and to defend in an orderly proceeding adapted to the nature of the case before a tribunal having jurisdiction of the cause.”); Reisman v. Ranoel Realty Co., 224 Pa. Super. 220 , 303 A.2d 511, 514 (1973) (arbitrations are not wholly informal proceedings and the basic principles of hearing conduct must be adhered to, with the arbitration process requiring for its

22
Allstate Insurance v. Fioravantigreen
pa · 1973 · cited in 2 Pennsylvania opinions naming this issue, 2009–2015
2 sentences

2015Co. v. Fioravanti, 451 Pa. 108 , 299 A.2d 585, 588 (1973) (once a dispute has been submitted to arbitration, the parties are entitled to a hearing with “the necessary essentials of due process, i.e., notice and opportunity to be heard and to defend in an orderly proceeding adapted to the nature of the case before a tribunal having jurisdiction of the cause.”); Reisman v. Ranoel Realty Co., 224 Pa. Super. 220 , 303 A.2d 511, 514 (1973) (arbitrations are not wholly informal proceedings and the basic principles of hearing conduct must be adhered to, with the arbitration process requiring for its

2015Co. v. Fioravanti, 451 Pa. 108 , 299 A.2d 585, 588 (1973) (once a dispute has been submitted to arbitration, the parties are entitled to a hearing with “the necessary essentials of due process, i.e., notice and opportunity to be heard and to defend in an orderly proceeding adapted to the nature of the case before a tribunal having jurisdiction of the cause.”); Reisman v. Ranoel Realty Co., 224 Pa. Super. 220 , 303 A.2d 511, 514 (1973) (arbitrations are not wholly informal proceedings and the basic principles of hearing conduct must be adhered to, with the arbitration process requiring for its

22
Elkin v. Bell Tel. Co. of Pennsylvaniagreen
pa · 1980 · cited in 4 Pennsylvania opinions naming this issue, 1993–2009
2 sentences

2009In Elkin v. Bell Telephone of Pa., 491 Pa. 123 , 420 A.2d 371 (1980), our Supreme Court recognized primary jurisdiction as originally being a federal doctrine and explained: The principles of the doctrine of primary jurisdiction are well settled.

2009In Elkin v. Bell Telephone of Pa., 491 Pa. 123 , 420 A.2d 371 (1980), our Supreme Court recognized primary jurisdiction as originally being a federal doctrine and explained: The principles of the doctrine of primary jurisdiction are well settled.

14
Commonwealth v. Mayfieldgreen
pa · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010
2 sentences

2010Commonwealth v. Mayfield, 574 Pa. 460, 832 A.2d 418, 422 (2003); Commonwealth v. Barud, 545 Pa. 297 , 681 A.2d 162, 165 (1996).

2010Commonwealth v. Mayfield, 574 Pa. 460, 832 A.2d 418, 422 (2003); Commonwealth v. Barud, 545 Pa. 297 , 681 A.2d 162, 165 (1996).

11
Commonwealth v. Barudgreen
pa · 1996 · cited in 1 Pennsylvania opinions naming this issue, 2010–2010
2 sentences

2010Commonwealth v. Mayfield, 574 Pa. 460, 832 A.2d 418, 422 (2003); Commonwealth v. Barud, 545 Pa. 297 , 681 A.2d 162, 165 (1996).

2010Commonwealth v. Mayfield, 574 Pa. 460, 832 A.2d 418, 422 (2003); Commonwealth v. Barud, 545 Pa. 297 , 681 A.2d 162, 165 (1996).

11
Goral v. Fox Ridge, Inc.green
pasuperct · 1996 · cited in 1 Pennsylvania opinions naming this issue, 2009–2009
2 sentences

2009Therefore, where a matter is submitted to arbitration, arbitrators are obliged to abide by the minimal procedural requirements necessary for common law ar *502 bitration which entails granting the parties a full and fair hearing. ¶ 16 In Goral v. Fox Ridge, Inc., 453 Pa.Super. 316 , 683 A.2d 931, 933 (1996) (internal citations omitted), we explained: Once it has been determined that the substantive dispute is arbitrable, all matters necessary to dispose of the claim are normally arbitrable as well.

2009Therefore, where a matter is submitted to arbitration, arbitrators are obliged to abide by the minimal procedural requirements necessary for common law ar *502 bitration which entails granting the parties a full and fair hearing. ¶ 16 In Goral v. Fox Ridge, Inc., 453 Pa.Super. 316 , 683 A.2d 931, 933 (1996) (internal citations omitted), we explained: Once it has been determined that the substantive dispute is arbitrable, all matters necessary to dispose of the claim are normally arbitrable as well.

11
Dudash v. Dudashgreen
pasuperct · 1983 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000“A corollary to the aforementioned principles is the rule that the mistake under scrutiny, as well as the actual intent of the parties, must be clearly proven.” Dudash v. Dudash, 313 Pa.Super. 547, 554-56 , 460 A.2d 323, 327 (1983), citing Hassler v. Mummert, 242 Pa.Super. 536, 538-39 , 364 A.2d 402, 403 (1976). ¶ 14 The Allstate adjuster states that at the time she extended the second offer to the Kramers’ attorney, she was unaware of the status of the personal injury case.

2000“A corollary to the aforementioned principles is the rule that the mistake under scrutiny, as well as the actual intent of the parties, must be clearly proven.” Dudash v. Dudash, 313 Pa.Super. 547, 554-56 , 460 A.2d 323, 327 (1983), citing Hassler v. Mummert, 242 Pa.Super. 536, 538-39 , 364 A.2d 402, 403 (1976). ¶ 14 The Allstate adjuster states that at the time she extended the second offer to the Kramers’ attorney, she was unaware of the status of the personal injury case.

11
Hassler v. Mummertgreen
pasuperct · 1976 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000“A corollary to the aforementioned principles is the rule that the mistake under scrutiny, as well as the actual intent of the parties, must be clearly proven.” Dudash v. Dudash, 313 Pa.Super. 547, 554-56 , 460 A.2d 323, 327 (1983), citing Hassler v. Mummert, 242 Pa.Super. 536, 538-39 , 364 A.2d 402, 403 (1976). ¶ 14 The Allstate adjuster states that at the time she extended the second offer to the Kramers’ attorney, she was unaware of the status of the personal injury case.

2000“A corollary to the aforementioned principles is the rule that the mistake under scrutiny, as well as the actual intent of the parties, must be clearly proven.” Dudash v. Dudash, 313 Pa.Super. 547, 554-56 , 460 A.2d 323, 327 (1983), citing Hassler v. Mummert, 242 Pa.Super. 536, 538-39 , 364 A.2d 402, 403 (1976). ¶ 14 The Allstate adjuster states that at the time she extended the second offer to the Kramers’ attorney, she was unaware of the status of the personal injury case.

11
Smith v. Thomas Jefferson University Hospitalgreen
pasuperct · 1993 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000See Smith v. Thomas Jefferson University Hosp., 424 Pa.Super. 41, 45-47 , 621 A.2d 1030, 1032 (1993) (citing McFadden, supra . ) "A corollary to the aforementioned principles is the rule that the mistake under scrutiny, as well as the actual intent of the parties, must be clearly proven." Dudash v. Dudash, 313 Pa.Super. 547, 554-56 , 460 A.2d 323, 327 (1983), citing Hassler v. Mummert, 242 Pa.Super. 536, 538-39 , 364 A.2d 402, 403 (1976). ¶ 14 The Allstate adjuster states that at the time she extended the second offer to the Kramers' attorney, she was unaware of the status of the personal inju

2000See Smith v. Thomas Jefferson University Hosp., 424 Pa.Super. 41, 45-47 , 621 A.2d 1030, 1032 (1993) (citing McFadden, supra . ) "A corollary to the aforementioned principles is the rule that the mistake under scrutiny, as well as the actual intent of the parties, must be clearly proven." Dudash v. Dudash, 313 Pa.Super. 547, 554-56 , 460 A.2d 323, 327 (1983), citing Hassler v. Mummert, 242 Pa.Super. 536, 538-39 , 364 A.2d 402, 403 (1976). ¶ 14 The Allstate adjuster states that at the time she extended the second offer to the Kramers' attorney, she was unaware of the status of the personal inju

11
Smith v. Swopegreen
ca9 · 1937 · cited in 1 Pennsylvania opinions naming this issue, 1997–1997
1 sentence

1997See Green, 732 F.2d at 1400 ; Smith v. Swope, 91 F.2d 260, 262 (9th Cir.1937); [White v.]Pearlman, 42 F.2d 788, 789 (10th Cir.1930) Martinez, 837 F.2d at 865 . 6 See Green, supra (the inadvertence of a marshal in failing to place a detainer on defendant amounted to mere negligence; it did not amount to violation of defendant’s due process rights and, thus, did not constitute either waiver or es-toppel; nevertheless, defendant was entitled to credit for time at liberty because he was released through the inadvertence of government agents through no fault of his own). 7 Citing to both Martinez a

11
Donald Wayne Green v. Robert Christiansen, Warden, Federal Correctional Institution, Lompoc, Californiagreen
ca9 · 1984 · cited in 1 Pennsylvania opinions naming this issue, 1997–1997
2 sentences

1997See Green, 732 F.2d at 1400 ; Smith v. Swope, 91 F.2d 260, 262 (9th Cir.1937); [White v.]Pearlman, 42 F.2d 788, 789 (10th Cir.1930) Martinez, 837 F.2d at 865 . 6 See Green, supra (the inadvertence of a marshal in failing to place a detainer on defendant amounted to mere negligence; it did not amount to violation of defendant’s due process rights and, thus, did not constitute either waiver or es-toppel; nevertheless, defendant was entitled to credit for time at liberty because he was released through the inadvertence of government agents through no fault of his own). 7 Citing to both Martinez a

1997See Green, 732 F.2d at 1400 ; Smith v. Swope, 91 F.2d 260, 262 (9th Cir.1937); [White v.]Pearlman, 42 F.2d 788, 789 (10th Cir.1930) Martinez, 837 F.2d at 865 . 6 See Green, supra (the inadvertence of a marshal in failing to place a detainer on defendant amounted to mere negligence; it did not amount to violation of defendant’s due process rights and, thus, did not constitute either waiver or es-toppel; nevertheless, defendant was entitled to credit for time at liberty because he was released through the inadvertence of government agents through no fault of his own). 7 Citing to both Martinez a

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (30)

CaseCitedYears
WESTON v. Reading Co. green
pa · 1971
2 sentences

2019In Bean, this Court further explained: Although the primary jurisdiction doctrine was originally a federal doctrine that was established by the United States Supreme Court in Texas [& Pacific Railway] v. Abilene Cotton Oil Co., [ 204 U.S. 426 , (1907)], our Supreme Court adopted it in Weston v. Reading Co., [ 282 A.2d 714 (Pa. 1971)], and further explained it in Elkin v. Bell Telephone of [Pennsylvania], [ 420 A.2d 123 , 371-376 (Pa. 1980)], as follows: The principles of the doctrine of primary jurisdiction are well settled.

2004Ry. v. Abilene Cotton Oil Co., 204 U.S. 426 , 27 S.Ct. 350 , 51 L.Ed. 553 , (1907), our Supreme Court adopted it in Weston v. Reading Co., 445 Pa. 182 , 282 A.2d 714 (1971), and further explained it in Elkin v. Bell Telephone of Pa., 491 Pa. 123, 132-133 , 420 A.2d 371 -376 (1980), as follows: The principles of the doctrine of primary jurisdiction are well settled.

31978–2019
Texas & Pacific Railway Co. v. Abilene Cotton Oil Co. green
· 1907
2 sentences

2019In Bean, this Court further explained: Although the primary jurisdiction doctrine was originally a federal doctrine that was established by the United States Supreme Court in Texas [& Pacific Railway] v. Abilene Cotton Oil Co., [ 204 U.S. 426 , (1907)], our Supreme Court adopted it in Weston v. Reading Co., [ 282 A.2d 714 (Pa. 1971)], and further explained it in Elkin v. Bell Telephone of [Pennsylvania], [ 420 A.2d 123 , 371-376 (Pa. 1980)], as follows: The principles of the doctrine of primary jurisdiction are well settled.

2004Ry. v. Abilene Cotton Oil Co., 204 U.S. 426 , 27 S.Ct. 350 , 51 L.Ed. 553 , (1907), our Supreme Court adopted it in Weston v. Reading Co., 445 Pa. 182 , 282 A.2d 714 (1971), and further explained it in Elkin v. Bell Telephone of Pa., 491 Pa. 123, 132-133 , 420 A.2d 371 -376 (1980), as follows: The principles of the doctrine of primary jurisdiction are well settled.

22004–2019
Jones v. Murphy green
pa · 1844
1 sentence

2025In Jones, the Court noted the party contesting the probated will bears the burden of proving “the factum of a subsequent will, and that it was suppressed or destroyed by fraud.” Jones, 8 Watts & Serg. at 295 .

12025–2025
Andrew v. CUNA Brokerage Services, Inc. green
pasuperct · 2009
1 sentence

2015Therefore, where a matter is submitted to arbitration, arbitrators are obliged to abide by the minimal procedural requirements necessary for common law arbitration which entails granting the parties a full and fair hearing. - 16 - J-A09028-15 Andrew, 976 A.2d at 501-02 .

12015–2015
Attix v. Lehman green
pasuperct · 2007
1 sentence

2011On appeal, this Court first explained our recent interpretation of the presumption in Rule 237.3(b) based on the principles of rule construction: [I]n Attix v. Lehman, 925 A.2d 864 (Pa.Super.2007), ... we concluded that a petitioner does not need to satisfy the common law requirement that he provide a reasonable excuse for the failure that led to the judgment by default, if his petition to open is filed within 10 days of the judgment and states a meritorious defense.

12011–2011
In Re PAB green
pa · 1990
2 sentences

2003Id., 570 A.2d at 525 . ¶ 26 After applying the aforementioned principles to our analysis of the trial court’s ruling, we reversed, holding: *1275 A determination that the [p]arents’ incapacity results in an inability to care for the children and that the condition cannot improve over time is alone insufficient to warrant termination under 2511(a)(5).

2003Id., 570 A.2d at 525 . ¶ 26 After applying the aforementioned principles to our analysis of the trial court’s ruling, we reversed, holding: *1275 A determination that the [p]arents’ incapacity results in an inability to care for the children and that the condition cannot improve over time is alone insufficient to warrant termination under 2511(a)(5).

12003–2003
Commonwealth v. Holzlein green
pasuperct · 1997
1 sentence

2002However, as we noted in Commonwealth v. Holzlein, 706 A.2d 848 (Pa.Super.1997), this Court’s authority to rectify an illegal sentence exceeds the principles of waiver and allows for sua sponte review.

12002–2002
Bond v. Workers' Compensation Appeal Board green
pacommwct · 1998
1 sentence

2000(Dr. Homonai’s deposition, p. 30.) The WCJ concluded, under the principles and analysis of our decision in Bond v. Workers’ Compensation Appeal Board (Belmont Center), 711 A.2d 554 (Pa.Cmwlth.1998), 4 that Claimant’s carpal tun *642 nel condition had resulted from a single incident on January 18, 1995, and dismissed AIG’s joinder petition. 5 The net effect of this determination was to place the risk with AIG as the carrier of record.

12000–2000
Brooks v. Workmen's Compensation Appeal Board green
pacommwct · 1993
1 sentence

2000The Board reversed this portion of the WCJ’s decision, relying on our decision in Brooks v. Workmen’s Compensation Appeal Board (Anchor Glass Container), 155 Pa.Cmwlth.248, 624 A.2d 821 (1993), petition for allowance of appeal denied, 536 Pa. 631 , 637 A.2d 291 (1993), 6 rendering EBI the responsible carrier.

12000–2000
Mayle v. Pennsylvania Department of Highways green
pa · 1978
2 sentences

2000Because our resolution of this issue directs us to venture into heretofore unexamined areas of the principles of immunity, a brief historical review of the law of immunity as it existed prior to Ayala and Mayle v. Pennsylvania Department of Highways, 479 Pa. 384 , 388 A.2d 709 (1978), superceded by statute, 42 Pa.C.S. § 8522(b) 4 would be in order.

2000Because our resolution of this issue directs us to venture into heretofore unexamined areas of the principles of immunity, a brief historical review of the law of immunity as it existed prior to Ayala and Mayle v. Pennsylvania Department of Highways, 479 Pa. 384 , 388 A.2d 709 (1978), superceded by statute, 42 Pa.C.S. § 8522(b) 4 would be in order.

12000–2000
White v. Pearlman green
ca10 · 1930
1 sentence

1997See Green, 732 F.2d at 1400 ; Smith v. Swope, 91 F.2d 260, 262 (9th Cir.1937); [White v.]Pearlman, 42 F.2d 788, 789 (10th Cir.1930) Martinez, 837 F.2d at 865 . 6 See Green, supra (the inadvertence of a marshal in failing to place a detainer on defendant amounted to mere negligence; it did not amount to violation of defendant’s due process rights and, thus, did not constitute either waiver or es-toppel; nevertheless, defendant was entitled to credit for time at liberty because he was released through the inadvertence of government agents through no fault of his own). 7 Citing to both Martinez a

11997–1997
United States v. Frank Martinez green
ca9 · 1988
1 sentence

1997See Green, 732 F.2d at 1400 ; Smith v. Swope, 91 F.2d 260, 262 (9th Cir.1937); [White v.]Pearlman, 42 F.2d 788, 789 (10th Cir.1930) Martinez, 837 F.2d at 865 . 6 See Green, supra (the inadvertence of a marshal in failing to place a detainer on defendant amounted to mere negligence; it did not amount to violation of defendant’s due process rights and, thus, did not constitute either waiver or es-toppel; nevertheless, defendant was entitled to credit for time at liberty because he was released through the inadvertence of government agents through no fault of his own). 7 Citing to both Martinez a

11997–1997
Commonwealth v. Ford green
pa · 1983
2 sentences

1997Commonwealth v. Ford, 315 Pa.Super. 281 , 461 A.2d 1281 , 1289 n. 11 (1983).

1997Commonwealth v. Ford, 315 Pa.Super. 281 , 461 A.2d 1281 , 1289 n. 11 (1983).

11997–1997
United National Insurance v. J.H. France Refractories Co. green
pasuperct · 1992
2 sentences

1995However, the court stated that in 1978, the legislature amended 42 Pa.C.S. § 5501, pertaining to statutes of limitation, and added subsection (c), which provides: “[t]his chapter is applicable to equitable matters, but nothing in this chapter shall modify the principles of waiver, laches, and estoppel and similar principles heretofore applicable in equitable matters.” Id. at 624, 612 A.2d at 1376 (quoting 42 Pa.C.S. § 5501(a)).

1995However, the court stated that in 1978, the legislature amended 42 Pa.C.S. § 5501, pertaining to statutes of limitation, and added subsection (c), which provides: "[t]his chapter is applicable to equitable matters, but nothing in this chapter shall modify the principles of waiver, laches, and estoppel and similar principles heretofore applicable in equitable matters." Id. at 624, 612 A.2d at 1376 (quoting 42 Pa.C.S. § 5501(a)).

11995–1995
Alford v. Philadelphia Coca-Cola Bottling Co. green
pa · 1987
2 sentences

1993Alford, 366 Pa.Super. at 513 , 531 A.2d at 794 .

1993Alford, 366 Pa.Super. at 513 , 531 A.2d at 794 .

11993–1993
Petty v. Suburban General Hospital green
pa · 1987
2 sentences

1993General Hospital, 363 Pa.Super. 277 , 525 A.2d 1230 (1987); Beatrice Foods, supra. This court has recognized that the application of the principles of the doctrine of forum non conveniens in both intrastate and interstate cases serves the same essential purpose: It provides the court with a means of looking beyond technical considerations such as jurisdiction and venue to determine whether litigation in the plaintiffs chosen forum would serve the interests of justice under the particular circumstances.

1993General Hospital, 363 Pa.Super. 277 , 525 A.2d 1230 (1987); Beatrice Foods, supra. This court has recognized that the application of the principles of the doctrine of forum non conveniens in both intrastate and interstate cases serves the same essential purpose: It provides the court with a means of looking beyond technical considerations such as jurisdiction and venue to determine whether litigation in the plaintiffs chosen forum would serve the interests of justice under the particular circumstances.

11993–1993
National League of Cities v. Usery red
scotus · 1976
1 sentence

1977It must be noted, however, that a negative answer or a qualified answer could easily be arrived at through application of the principles and analysis set forth in National League of Cities v. Usery, 426 U.S. 833 (1976).

11977–1977
Spinelli v. United States red
scotus · 1969
11973–1973
Collins v. Collins green
pasuperct · 1954
11963–1963
United Mine Workers v. Patton green
scotus · 1954
11963–1963
Glover v. Officers of the Congregational Church green
scotus · 1954
11963–1963
Redding v. Texas green
scotus · 1954
11963–1963
Goldstein v. Hunter green
ny · 1931
11947–1947
Nanty-Glo Boro. v. American Surety Co. green
pa · 1932
11937–1937
Dzsujko v. Eureka-Maryland Assurance Corp. green
pasuperct · 1933
11937–1937
Fowler v. Scully ex rel. First National Bank green
pa · 1873
11900–1900
Williamson v. Lewis green
pa · 1861
11899–1899
Martin v. M'Cord neutral
pa · 1836
11866–1866
Morrison v. Beirer neutral
pa · 1841
11866–1866
Helmbold v. Man neutral
· 1839
11839–1839

Where else courts name it

IL 117 (1958–2026) CA 51 (1895–2026) PA 33 (1839–2025) MD 22 (1909–2020) MO 21 (1890–2024) NY 21 (1859–2018) NJ 18 (1945–2023) GA 17 (1939–2015) TX 17 (1910–2026) NC 16 (1994–2022) IA 16 (1939–2026) MN 15 (1987–2025) WI 14 (1975–2019) OH 14 (2005–2024) CT 11 (1972–2016) MI 11 (1983–2023) TN 11 (1905–2015) FL 10 (1962–2016) WV 10 (1903–2026) AL 9 (1940–2008) VT 8 (1972–2026) VA 8 (1966–2020) OK 8 (1900–2015) MS 7 (1895–2025) ID 6 (1983–2025) OR 6 (1977–2025) MA 6 (1937–2025) KS 5 (1925–2021) WA 5 (1972–2020) UT 5 (1996–2024) LA 5 (1998–2025) RI 4 (1960–2004) DE 4 (1939–2015) NM 3 (2009–2024) WY 3 (1988–1997) IN 3 (1898–2014) CO 3 (1947–2025) AZ 3 (2010–2025) SD 3 (1957–2007) DC 3 (1979–2012) NV 3 (2009–2021) MT 3 (1927–2008) KY 2 (1965–2025) AR 2 (1909–2012) ME 2 (1973–2020) HI 2 (1946–1995)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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